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Debt/equity: comments on recent developments, overseas experiences and Section 974-80 paper

Published on 17 Nov 05 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

This paper covers:

  • the distinction between debt and equity
  • comments on the US, UK and Canadian experience
  • current issues:
    • effect of solvency clauses for project finance, lower tier 2 capital
    • what if you cannot institute winding-up proceedings on a default by a company?
    • the effect of conversion rights and options, including TD 2004/D76
  • the ambit of section 974-80.

Author profiles

Martin Fry FTI
Martin has been a Partner in the Allens Tax Group for over fifteen years, and has focused on resource companies, banks and infrastructure projects. He has extensive experience advising on the tax aspects of capital management transactions for ASX-listed companies, most recently in relation to Rio Tinto's 2015 off-market tender share buyback and on-market share buyback. He has also advised APRA-regulated banks on the tax aspects of hybrid equity and subordinated debt instruments. He advises consortia and financiers on the tax aspects of project finance for major infrastructure projects including M2, M5 and M7 motorways, among others. He is a Senior Fellow of the Law Faculty of the University of Melbourne. - Current at 30 August 2017
Click here to expand/collapse more articles by Martin FRY.
Martin Fry FTI
Martin has been a Partner in the Allens Tax Group for over fifteen years, and has focused on resource companies, banks and infrastructure projects. He has extensive experience advising on the tax aspects of capital management transactions for ASX-listed companies, most recently in relation to Rio Tinto's 2015 off-market tender share buyback and on-market share buyback. He has also advised APRA-regulated banks on the tax aspects of hybrid equity and subordinated debt instruments. He advises consortia and financiers on the tax aspects of project finance for major infrastructure projects including M2, M5 and M7 motorways, among others. He is a Senior Fellow of the Law Faculty of the University of Melbourne. - Current at 30 August 2017
Click here to expand/collapse more articles by Brad SCHWARZ.

 

This was presented at Corporate Tax Intensive - Tough Tax Topics .

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